Co-operative society's mandatory reserve and share capital fixed deposits with banks-interest treated as business income under 80P(2)(a)(iii) deductio...
Income tax reassessment reopening after four years on investigation tip, without s.147 proviso disclosure failure, struck down as borrowed satisfactio...
For assessments under s.153C, the block period must be computed with reference to the date on which the seized books/documents/assets are received by the jurisdictional AO of the non-searched person, and not from the date of initiation of search. This follows the statutory scheme that uses "immediately preceding" for identifying the six assessment years, while Explanation 1 to s.153A requires the extended ten-year period to be reckoned "from the end of the assessment year," i.e., from 31 March of the AY relevant to the year of search; the computation must therefore align with these distinct legislative phrases. - ITAT
For assessments under s.153C, the block period must be computed with reference to the date on which the seized books/documents/assets are received by the jurisdictional AO of the non-searched person, and not from the date of initiation of search. This follows the statutory scheme that uses "immediately preceding" for identifying the six assessment years, while Explanation 1 to s.153A requires the extended ten-year period to be reckoned "from the end of the assessment year," i.e., from 31 March of the AY relevant to the year of search; the computation must therefore align with these distinct legislative phrases. - ITAT
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